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In such instances, it appears that the better technical view is that the consideration granted by both the farmee and farmor is sufficiently difficult to value that, notwithstanding the obvious disposition, no sufficiently precise amount may De considered receivable to support the argument that there are proceeds of disposition. ...

The predecessor to paragraph 81(1)(c) considered in the case provided that: 10(1) There shall not be included in computing the income of a taxpayer for a taxation year... ...

However, for purposes of the Canada-Germany Income Tax Convention, these deemed residents of Canada are also considered residents of Germany by virtue of Article 4 of the Convention (because their center of vital interest is in Germany). ...

Factors to be considered identified by the Handbook are representation on the board of directors, participation in policy-making processes, material intercompany transactions, interchange of management personnel or provision of technical information. ...

It is our view that, pursuant to subsection 248(5), the voting shares would be considered to be property substituted for the non-voting shares. ...

You suggested that paragraph 88(1)(d.2) might not be applicable in this case if the will provisions described were considered to come within the exception in that paragraph. ...

(a) The terminology used gives rise to some confusion, particularly when the references to "1989 allowable capital losses" in Notes 1 and 2 and to "allowable capital loss for 1989" in line (N) are considered together. ...

However, in situations in which an individual transfers all of his shares of Opco to a Holdco the other shareholders of which are individuals who have effected the transfer of all their shares of Opco, as in the example described above, such transfer will not be considered to have been made after the commencement of the series of transactions for the purposes of subsection 55(2) of the Act. ...

Where the value of a loan receivable denominated in Canadian dollars has increased, the capital gain on such a loan can be deferred as the result of the application of the above rollover positions because the cost amount of the loan receivable is considered to be the amount of the loan expressed in terms of the amount of money which is the outstanding balance of the loan. 2. ...

(g) Even the addition of a preferential cumulative dividend does not necessarily maintain the value of the freeze shares because the risk of investing the principle for such a long period of time would have to be considered but such a feature would add more value to the freeze shares. ...